Wednesday, November 30, 2016

The New ACA Form 1095-C Codes

Let’s switch gears here for a post and talk about the Affordable Care Act Forms. More specifically, Form 1095-C and the changes it’s gone through to be ready for 2016 filing early next year.

If you filed 1095-C Forms this past year, you may recall on lines 14 and 16 you were required to enter codes that corresponded with the type of coverage you offered and the safe harbor relief for which you were eligible. These codes were chosen from Code Series 1, Offer of Coverage, and Code Series 2, Section 4980H Safe Harbor Codes and Other Relief for ALE Members, respectively.

Code Series 1 Changes
This past year, Code Series 1 provided a variety of codes, numbered 1A to 1I, to indicate more information about the coverage offer you provided to the employee. But for 2016 filing, this code is a little different.

For one thing, code 1I, which only applied for 2015 transitional relief options, is no longer available and is marked as “reserved” by the IRS. In other words, don’t use it on any future forms.

For another, codes 1J and 1K were added to the list. Codes 1J and 1K address conditional offers of spousal coverage. A conditional offer refers to an offer of coverage that is subject to one or more objective conditions, which must be found reasonable to the IRS. An example of an appropriate conditional offer would be an offer to cover an employee’s spouse only if the spouse is not eligible for coverage under a group health plan sponsored by another employer or Medicare.

Code 1J: Minimum essential coverage providing minimum value is offered to the employee and at least MEC is conditionally offered to the spouse. MEC is not offered to the dependent(s).
Code 1K: MEC providing minimum value is offered to the employee and dependent(s) and at least MEC is conditionally offered to the spouse.

Code Series 2 Changes
Code Series 2 was a little bit different than the first series because not everyone would necessarily use it. Code Series 2, with codes 2A to 2I, is used to indicate the safe harbor relief for which you may be eligible.

This coming year, for the 2016 filing season, code 2I is no longer applicable. Similar to code 1I, code 2I only applied for a 2015 safe harbor relief option, so, naturally, it can’t be used past the tax year 2015.

We’ll be sure to keep you updated on any major ACA changes in the coming months to help make sure you’re as prepared as possible for the 2016 filing season. And if you have any questions in the meantime or need to e-file Form 1095-C, don’t hesitate to give ExpressIRSForms a call! We’re available by phone (704-684-4751) and live chat (through our site) Monday through Friday, 9:00 a.m. to 6:00 p.m. EST. We also provide 24/7 customer support via email at

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